of the companies REALISM Development s.r.o., ID No.: 03496147, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 231831 (the „REALISM Development“) and other companies in the REALISM group, to which, besides REALISM Development, belong the companies REALISM s.r.o., ID No.: 085 30 891, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 320473, REALISM Construction s.r.o., ID No.: 041 86 389, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 243850, REALISM Asset s.r.o., ID No.: 054 07 559, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 263213, REALISM Outsourcing s.r.o., ID No.: 052 70 511, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C261012, REALISM Projects s.r.o., ID No.: 08944903, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 327970, T.E Bleriot s.r.o., ID No.: 04549678, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 249562, Top.Estates Sakura s.r.o., ID No.: 24202401, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 188214, Top.Estates Carpentry s.r.o., ID No.: 035 14 706, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 232549, Top.Estates Zahrada s.r.o., ID No.: 041 86 231, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 243848, IRQ management s.r.o., ID No.: 09368043, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 335239, IMPERATIO s.r.o., ID No.: 09322213, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 334448, IRQ FUNDS SICAV a.s., ID No.: 09610863, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. B 25754, Projekt Přezletice s.r.o., ID No.: 08537470, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 320610,

(the “REALISM Group”)

Dear Sir or Madam,

Thank you for your trust in us by granting your consent to the processing of personal data for their use to informing, communicating and ensuring the smooth implementation of your chosen product, or product under the contract with respect to the product we offer, and/ or for use for the purpose of offering products and services, i.e. the marketing purposes of the REALISM Group and the third parties listed below. In the following text, we bring you detailed information that is important for a proper understanding of the consent.

The REALISM Group fully respects your right to privacy when you visit our websites and whether you communicate with us in person, by telephone and/ or electronically. We take all necessary measures and do our utmost to secure any personal information you provide to us.

We need this consent from you so that, due to the requirements of the new European legislation in the field of personal data protection (EU Regulation No. 2016/679) and subsequent and related Czech legislation, we can ensure informing, communication and smooth implementation of your chosen product, or product under the contract with respect to the product we offer, and/ or for use for the purpose of offering our products and services that are tailor-made for you and, conversely, did not overwhelm you with offers that might not interest you.

In this document the following is explained:

What information do we process for marketing and business purposes?

What sources does this information come from?

For which purposes do you grant consent?

Who do you grant the consent to?

Who can process your data?

How long do we keep personal data?

How can you withdraw your consent?

What are your legal rights when processing personal data?

1. What information do we process for marketing and business purposes?

We are open to you, therefore it is important for us that you know how we process your personal data and for which purposes we use it. The data that we will process on the basis of your consent include: name and surname, birth number (in the case of entrepreneurs also the business name, identification number and registered office), date of birth, contact information, socio-demographic data, information on the use of products and services, information from applications for products and services, information from telephone call records or other interactions between you and us, transaction data (bank account number and your banking entity), geolocation data, information from the web browser you use and data that we process to fulfil our legal obligations or for the purpose of our legitimate interests. This is data that we obtain directly from you, from public sources (including information from social networks and the Internet that you publish about yourself), from surveys and user testing, or from cooperating third parties.

In the following section, we will present you what personal data is involved, including examples:

Basic Identification Data

In particular, the name, surname, birth number and date or place of birth (in case you run your own business, it can also be the identification number and address of the place of business) are important for us to make sure that we really contact the right person. In addition, we would like to address you by your name.

Contact Data

In particular, the delivery address, telephone or e-mail are necessary for us to be able to deliver the information, offer or our communication to you.

Socio-Demographic Data

These are classic statistical data, for example, place of residence, gender, status (single, divorced…), etc. You provide this information about yourself to us when searching for products or we derive it from other data that we have about you.

Transaction Data

Our systems record every payment made for the purchase of our products, including the account number from which the payment was made.

Direct Channels, Data from Internet Browser and Applications

Besides visiting the REALISM Development office and/ or the REALISM Group office or telephone contact, you can also contact us via e-mail communication and/ or via social networks (e.g. Facebook, Instagram, Twitter, LinkedIn) and also e.g. via the contact form and the form for subscription to the newsletter on the web and form on social networks (e.g. FB Lead Ads).

When you log in, you automatically send the IP address of your computer. Therefore, we can detect the number of the network and subnetwork in which your computer is located. If you have enabled the saving of so-called cookies in your browser, you send through them additional information to us, for example about the sites you visit, about user preferences on your computer, etc. We use information about your operating system (for example Windows or MacOS), its version and technical data about the devices from which you are logging in (for example the type of your smartphone). This helps us to constantly improve our services and adapt them to your technical capabilities.

Information About Use of Products and Services

For better targeting in our campaigns, we use information about what products you have already agreed with us, when you have agreed them, under what conditions, whether you still use them or have cancelled them. We know how often you log in to our internet application and whether you have taken an action in their environment (for example arranging a meeting with a consultant) or if you have logged out after a while.

Information About Contact with You

In order to prevent us from contacting you more than once for the same reason, we record information about contacts between you and us. This is especially the data, such as the date (or time) of the contact, its reason, and whether the contact was initiated by you or us. This applies to contacts via all channels - telephone, SMS, chat, mail, e-mail, data box, personal meeting with the advisor at the branch/ advisory point or via the Internet application or other applications. If it was an offer from us, we always record your reaction - whether you liked the offer or not. This is so that we do not offer you a product that did not appeal to you again. In the application designed for this, we also make notes from conversations between you and our consultants in order to better orient ourselves in your needs.

Telephone Calls Records

When you call us or we call you, we may ask you for additional consent to record the call at the beginning of the call. In other cases, we shall record calls with you in order to fulfil legal obligations or to be able to prove that we have followed your instructions exactly or that a valid contract has actually been concluded (or for other reasons falling into the category of "legitimate interests of the controller", see below). We will always inform you in advance about this recording. Based on your marketing consent, we can also process these recordings for marketing purposes. We also rewrite the recordings into text form and then analyse them through so-called text analysis. We store structured notes from the analysis, such as what we talked about or how you reacted to the product offer - so you don't have to repeat it to us next time.

Information from Social Networks

Upon implementation of our marketing campaigns, we also work with Facebook (hereinafter "FB"), LinkedIn, Instagram and Twitter. We do not store the data you publish on your main page, but we use it to better target our campaigns.

External Sources

Sometimes our own data is not enough for us to target properly. Therefore, in order to be absolutely sure that our offer is suitable for you, we also use information from external sources. These are mainly publicly available registers, such as the Commercial Register, the Register of Economic Entities, the Register of Debtors, Profession Registers, etc.

Surveys and User Testing

When we prepare a new product or we want to know the opinion on our existing products and ads, or we want to find out what services would be liked, we ask you, our clients directly in various surveys. The outcome of such surveys are the average results for the whole group of respondents, never at the level of individuals, but we also inspire ourselves by specific statements. This is a little different for the development of new offers and/ or services - in addition to asking respondents how they like the new application designs, we do user testing with them. These tests will allow us to determine whether the application is interesting, and also easy to use.

Data that we are processing about you in order to fulfil our legal obligations

This is data that we primarily have to collect, evaluate and maintain for a set period of time, because it is a matter of fulfilling our legislative obligation. This includes, for example, the archiving obligation under various laws governing our business, the acquiring and evaluation of data for the purpose of fulfilling obligations in the prevention of money laundering (e.g. KYC, "Know Your Client") and a number of other laws. The examples are: sources and origin of income, capital interconnection, nationality, place of residence, subject of activity, etc. Based on your consent, we will be able to process this data for marketing purposes.

2. What sources does this information come from?

The data processed under the consent comes from various sources. It is most often provided by the client himself. In many cases, the REALISM Group creates data for further processing (analyses, reports, etc.). We also use other information we obtain about the client as part of our activities, from public sources (such as public lists and registers, Internet applications, social networks, other public information sources) or from cooperating third parties. All this data is processed jointly by the entire REALISM Group and can also be passed on between controllers. This means, for example, that the information you provide about yourself to a REALISM Development consultant is also available to other companies of the REALISM Group for marketing purposes. At the same time, this means that we also share publicly available information about you.

3. For which purposes do you grant consent?

The purpose of personal data processing means the offer of products and services provided by the REALISM Group or cooperating third parties listed below, including through electronic channels, as well as marketing processing, analyses and profiling in order to adapt our offer to your needs and ensure and improve the services we provide.

With the client's consent, we process their personal data primarily with the aim of ensuring the smooth implementation of your chosen product, or product under the contract with respect to the product we offer, and/ or for use for the purpose of offering products and services, and creating a suitable offer of products and services provided by the REALISM Group. We do not want to bother our clients with unnecessary and inappropriate communication, so we use the collected personal data to better understand their needs and be able to offer them suitable products. It can be a product offering, service communication, a satisfaction survey or a birthday congratulations.

We use a wide range of channels to communicate with you - regular mail, e-mail communication (individual e-mail messages and bulk newsletters), telephone, SMS messages, communication on social networks or also "pop-up windows" in the Internet application.

Information about the use of our products and services helps us to monitor and constantly improve their quality and maintain the favour of our clients. We further process the personal data of our clients to support business decisions and identify business potential, assess the suitability of the offer for a particular client, to submit an offer, as well as to verify the correct functionality of products and services provided to clients in internal systems.

The actual use of data is preceded by its processing, it is mainly the so-called marketing data processing. Under this, you can imagine statistical and mathematical analyses in order to gain insight into the client's behaviour and estimate their future behaviour or business potential, as well as client profiling, various segmentations, reporting, etc. Processing can be both manual and automated.

In the event that you have previously granted, or will grant in the future, marketing consent also directly to an individual company in the REALISM Group (see above), the particular company in the REALISM Group will also process the data defined above together with other data available for marketing purposes in connection with the products and services they offer.

4. Who do you grant the consent to?

You grant your consent to the company REALISM Development and other companies of the REALISM Group, specified in the introduction hereof, which are: REALISM s.r.o., ID No.: 085 30 891, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 320473, REALISM Construction s.r.o., ID No.: 041 86 389, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 243850, REALISM Asset s.r.o., ID No.: 054 07 559, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 263213, REALISM Outsourcing s.r.o., ID No.: 052 70 511, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C261012, REALISM Projects s.r.o., ID No.: 08944903, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 327970, REALISM Project I s.r.o., ID No.: 04304781, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 245650, REALISM Project II s.r.o., ID No.: 04852516, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 254680, REALISM Project III s.r.o., ID No.: 04992784, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 256726, T.E Bleriot s.r.o., ID No.: 04549678, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 249562, Top.Estates Sakura s.r.o., ID No.: 24202401, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 188214, Top.Estates Carpentry s.r.o., ID No.: 035 14 706, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 232549, Top.Estates Zahrada s.r.o., ID No.: 041 86 231, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 243848, IRQ management s.r.o., ID No.: 09368043, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 335239, IMPERATIO s.r.o., ID No.: 09322213, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 334448, IRQ FUNDS SICAV a.s., ID No.: 09610863, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. B 25754, Projekt Přezletice s.r.o., ID No.: 08537470, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Praha 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 320610 and further to third persons, i.e. natural and juridical persons cooperating with REALISM Development and/ or companies of the REALISM Group or with one of them/ with more or all of them, as the processors (see article 5 below).

In accordance with the legal definition, a personal data controller is any entity that determines the purpose and means of personal data processing, performs their collection, processing and maintenance for the purpose specified by it.

All the companies listed above act as so-called joint controllers or processors of your personal data. Therefore, for the purposes stated in the consent, they may share and process the data stated in the consent.

Upon granting of the consent and later, it is not possible to choose which companies will be granted the consent and which will not. We will therefore consider your possible disagreement with the inclusion of only some of the mentioned joint controllers or processors as non-granting, resp. withdrawal of this marketing consent.

5. Who can process your data?

The regulation of personal data protection allows the controller to authorize the processor to the processing of personal data. A processor of personal data is any entity that processes personal data on the basis of a special law or authorization by the controller. In some cases, this procedure is also used by REALISM Group companies when processing personal data for marketing and/ or business purposes. In such cases, the same protection of your data is guaranteed by contract and regulation as is guaranteed by the controller. The following companies are among the most important processors that the companies of the REALISM Group use for the processing of personal data for marketing and/ or business purposes:

Design&Co, s.r.o., ID No.: 29021235, with its registered office at Klimentská 1207/10, 110 00 Praha 1 - Nové Město, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 160497, NACONI s.r.o., ID No.: 24215121, with its registered office at Rubeška 215/1, 190 00 Praha 9 - Vysočany, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 189371, REALPAD Software, odštěpný závod, ID No.: 02511371, with its registered office at Táborská 940/31, 140 00 Praha 4 - Nusle, registered in the Commercial Register held by the Municipal Court in Prague under file No. A 76420, KOFEIN s.r.o., ID No.: 03055540, with its registered office at Chrudimská 2526/2a, 130 00 Praha 3 - Vinohrady, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 226903, Breezy s.r.o., ID No.: 27733823, with its registered office at Plzeňská 157/98, 150 00 Praha 5 - Košíře, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 163153, OM Consulting s.r.o., ID No.: 02154439, with its registered office at Sokolovská 668/136d, Karlín, 186 00, Praha 8, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 216227, J.B. – BABYLON, spol. s r.o., ID No.: 63670232, with its registered office at Křenova 439/21, Praha 6, 162 00, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 37833, OKIN FACILITY, a.s., ID No.: 27102378, with its registered office at Velkopřevorské náměstí 488/5, Malá Strana, 118 00, Praha 1, registered in the Commercial Register held by the Municipal Court in Prague under file No. B 9017, AMISTA investiční společnost, a.s., ID No.: 27437558, with its registered office at Sokolovská 700/113a, 186 00 Praha 8, registered in the Commercial Register held by the Municipal Court in Prague under file No. B 10626.

6. How long do we keep personal data?

You give your consent to REALISM Development and other companies of the REALISM Group and it remains valid and effective for the duration of our offer and the approval and/ or termination of the contract for your selected product and for the next three (3) years or until you withdraw your consent.

In the event that you do not become our client (i.e. no contractual relationship is established with REALISM Development or another company of the REALISM Group), your consent will be valid for three (3) years from the date of its granting. Upon expiration and effectiveness of the consent, your personal data will be deleted or processed only to the extent and for purposes for which consent is not required by law.

7. How can you withdraw your consent?

The consent is voluntary, you can refuse to grant it or withdraw the granted consent at any time, at REALISM Development or at any company of the REALISM Group. Non-granting or withdrawal of the consent has no effect on your contractual relationship with any of these companies or on the use of their products and services for which such consent is not required. If you withdraw the consent at one of these companies, this withdrawal will also apply to the other companies, which means that none of them will be able to further process your personal data for the purposes stated in the consent after this date. In the event of withdrawal of the consent, we will assume that you no longer wish to continue processing your personal data for marketing and/ or business purposes, even on the basis of any previously granted consents or any specific consents. Therefore, we will continue to consider such additional marketing and / or commercial approvals as withdrawn.

8. What are your legal rights when processing personal data?

You have the right to ask us to provide information about the personal data processed about you, the purpose and nature of personal data processing and the recipients of personal data. If you find or believe that we are processing your personal data in violation of the protection of your private and personal life and/ or in violation of the law, you are entitled to request an explanation from us, or to request the defective state to be remedied. You also have the right to contact the Office for Personal Data Protection in the event of a breach of our obligations to seek remedial action.

REALISM Development s.r.o., ID No.: 03496147, with its registered office at U měšťanského pivovaru 1417/7, Holešovice, 170 00 Prague 7, registered in the Commercial Register held by the Municipal Court in Prague under file No. C 231831 and REALISM Group